Select Committee on Transport, Local Government and the Regions Memoranda

Memorandum by McCarthy and Stone (PGP
13)

Memoranda to the Select Committee for Transport,
Local Government and the Regions on Planning: delivering a fundamental
change and the accompanying papers on Major infrastructure projects,
Reforming planning obligations and Compulsory purchase and compensation.

McCarthy and Stone, as the UK's major provider
of private sheltered accommodation for the elderly, has a very
strong interest in the proposed reforms to the planning system
and hence welcomes the opportunity to be able to submit views
on the proposals to the Select Committee. Our views are as follows:

The effectiveness of the system of local plans
and the Government's proposals to replace them

We welcome the overriding objectives of the
Planning Green Paper, to speed up the planning system and make
it more effective and able to bring about good planning. However,
in our opinion the problem with the current system is not its
structure but the way in which the present system is interpreted
and implemented.

For example the abuse of Circular 1/97; the
slow processing of planning applications; the lack of priority
given to brownfield development and/or schemes for special needs
housing; the objection to high density housing; and the general
resistance to change. Much more could be achieved through proper
enforcement of existing policy and legislation. Therefore we do
not believe that the Local Plan system needs to be radically reformed.
Instead the Government could cut burdens on Local Authorities
by reducing the need for overlapping strategies, such as community
strategies whose precise role seems unclear to us and where many
of the objectives would be very similar to those of Local Plans
or the proposed Local Development Frameworks. Furthermore, removing
material from Local Plans that is not sensitive to local variations,
such as development control and design standards, listed building
polices, conservation policies, access and car parking standards
will simplify and speed up the problem. Above all, the Secretary
of State should be prepared to apply sanctions to local councillors
that do not adhere to national policy and guidelines.

In terms of the proposals for LDFs and Action
Plans, we are concerned that Action Plans will take longer to
produce or will not be produced with the same time discipline
as the LDFs. We find it hard to envisage that the new system will
create more certainty for interested parties.

The role of regional planning bodies

McCarthy and Stone supports the proposal to
simplify the hierarchy of plans but believe that it will be necessary
to strengthen the scope and quality of regional planning in order
to do this. It is our view that regional plans are currently inadequate
to replace the county structure plans. It will be vital for the
Regional Planning Bodies to consult far more widely and effectively
in the future if this is to be achieved.

In our view the regional level is the most appropriate
for addressing the implications of predicted social, economic
and environmental change for the planning system. One example
of this is the projected growth in the number of older people
(by 2016 one million more single pensioner households will exist).
Currently there are no housing strategies that consider the implication
of this future change and we believe this should be addressed
at the regional level.

Proposed changes to planning obligations and CPOs

The Government's proposals to replace planning
obligations with a development tariff are fundamentally flawed
and if introduced in the form outlined in the White Paper would
seriously jeopardise the future development of brownfield sites.
The reason for this is that the proposed tariff would not be linked
with, or reflect, the social or environmental impact of the development
or the cost of developing the site. We speak with experience as
all McCarthy and Stone schemes are built on brownfield sites that
have significant costs associated with bringing development forwardincluding
demolition, decontamination, noise attenuation, tree protection
and highways contributions. In addition to this, the fact that
we build Category II type sheltered housing means that 30 per
cent of each McCarthy & Stone development is non-salable consumer
space.

To set the tariff using simple criteria such
as floor space would prejudice heavily constrained urban brownfield
sites from being developedit is wholly inappropriate to
apply the same level of tariff to a small brownfield site as to
a small greenfield site! We also believe that affordable housing
policy should only be applied to sites greater than 0.5 hectares,
irrespective of the number of dwellings proposed, as smaller sites
are unsuitable for and incapable (physically and/or economically)
of, accommodating a mix of housing types.

Furthermore we would be extremely concerned
about the lack of scrutiny there would be over the levels at which
tariffs would be set and how the income would be spent by each
local authority. In fact McCarthy and Stone fundamentally opposes
the very principle behind this tariff, that a developer should
pay for wider community services that bear no relation to his
development. At the end of the day it is the consumer (who in
our case is typically a widow in her mid 70s) who pays with higher
property prices.

Whether the Government's proposals will simultaneously
increase certainty, public participation and faster decisions,
particularly for business

On average it takes McCarthy and Stone 12-13
months to secure a planning consent for a typical Category II
type sheltered housing scheme. We agree that there is a genuine
and urgent need to speed up the planning system. The Green Paper
contains some proposals that would improve the planning system,
but many that would not or that we are unclear about at this stage.

In our view, the following proposals would speed
up the planning system:

 Fast track mediation.

 Statutory planning performance targets.

 Better resourcing of planning departments.

 90 per cent of all applications being
dealt with by delegated authority to officers.

 Simplifying the development plan
process by abolishing structure plans.

 Making an independent Chair or Inspector's
report on a planning appeal binding.

The following proposals would however slow down
the system and cause more delay:

 More community consultation at all
levels (without mandatory deadlines).

 Removal of crown development from
planning controls.

 Reasons for approval.

 Opening up committee meetings to
public debate.

 Removal of facility to duplicate/twin
applications which is an important means of trying to achieve
greater discipline amongst authorities.

 The proposed LDFs and Action Plans.

 Removal of the public local inquiry
into a draft LDF and Action Plan.

Planning's contribution to the urban renaissance.

Whilst McCarthy and Stone welcomes the spirit
and principles behind the Planning Green Paper we are extremely
disappointed that it hails fundamental reform without tackling
the fundamental problems that lie behind the failings of the current
system. The real challenge is for the Government to nurture more
positive attitudes towards development, and to make more people
understand that it is development that brings about urban renaissance.

It is our view that negative attitudes, not
complexity, are the underlying problem. Whilst we acknowledge
that some development is controversial, McCarthy and Stone's developments
are not and yet we still experience considerable difficulties
in achieving a planning consent. On many occasions we have been
refused planning permission because of local concernssuch
as the density of development; an allegation of inadequate car
parking; the loss of an existing use, (even though such use can
be shown to no longer be economic or beneficial); and, a general
resistance to change!

We also believe that there is considerable scope
at all levels for greater consideration and understanding of the
implications of social, economic and environmental change for
the planning system. Local authorities and central government
currently seem to be stuck in the groove of affordable housing,
affordable housing, affordable housing... despite the lack of
high quality compliance needs assessments and, controversial as
it sounds, an overestimation of the need for affordable housing
over other types of housing in some areas.

Finally, in order to really speed up the development
of brownfield sites we believe there should be a formal presumption
in favour of brownfield development. At McCarthy and Stone, we
would take this one step further and argue that given both present
and future need for housing for the elderly, there should be a
formal presumption too, in favour of sheltered housing and other
forms of special needs housing to ensure an adequate supply for
future generations.